ML20203G667
| ML20203G667 | |
| Person / Time | |
|---|---|
| Issue date: | 02/11/1999 |
| From: | Charemagne Grimes NRC (Affiliation Not Assigned) |
| To: | Walters D NUCLEAR ENERGY INSTITUTE (FORMERLY NUCLEAR MGMT & |
| References | |
| PROJECT-690 NUDOCS 9902220020 | |
| Download: ML20203G667 (6) | |
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1 U MITED STATES g
j NUCLEAR REGULATORY COMMISSION I
WASHINGTON, D.C. 20086 4001 February 11, 1999 Mr. Douglas J. Walters Nuclear Energy Institute 1776 l Street, N.W., Suite 400 Washington, DC 20006-3708
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION REGARDING GENERIC l
i LICENSE RENEWAL ISSUE 98-0102 " SCREENING OF EQUIPMENT THAT IS KEPT IN STORAGE"
Dear Mr. Walters:
As you are aware, the staff has been tracking several generic license renewalissues. The staff has identified an additional generic renewal issue regardirig excluding equipment from an aging management review that meets the scoping criteria of 10 CFR 54.4 but is kept in storage. The purpose of this letter is to define the issue and request additional information from the industry to j
aid the staff in resolving the issue. The issue has been assigned generic license renewal issue number 98-0102. Below is an example from the review of a license renewal application that illustrates the staff's concern.
The example revolves around pump motors, switchgear and electrical cables that are stored in warehouses on-site to comply with Appendix R to 10 CFR Port 50. Specifically, Appendix R Section Ill.L.5 provides that fire damage to equipment and systems comprising the means to achieve and maintain cold shutdown shall be limited so that the systems can be made operable (i.e., repaired) and cold shutdown achieved within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after a fire accident. In this example the design basis documents state that repairs, including replacement of power cab!ing, pump motors, valve operators, and switchgear associated with the low pressure injection, high pressure injection, or low pressure service water may be required for cold shutdown. The design basis document also states that all the components necessary to achieve all repairs are stored on-site.
The electrical cables that are stored in warehouses to comply with 10 CFR Part 50 Appendix R requirements were considered to be within scope of the license renewal rule in accordance with 10 CFR 54.4(a)(3) and were subject to an aging management review in accordance with 10 CFR 54.21(a)(1). However, the stored pump motors and switchgear were not subject to an aging management review because 10 CFR 54.21(a)(1)(i) identifies motors and switchgears to be j
excluded from the structures and components that perform an intended function without moving parts or without a change in configuration or properties.
The statements of considerations (SOC) for the license renewal rule,10 CFR Part 54, dated k
May 8,1995, states O
Performance and condition monitoring for systems, structures, and components typically involves functional verification, either directly or indirectly. Direct 1)Yg.;
verification is practical for active functions such as pump flow, valve stroke time,
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or relay actuation where the parameter of concern (required function), including any design margins, can be directly measured or observed.
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' Douglas J. Walters February 11, 1999 i
On the basis of consideration of the effectiveness of existing programs which monitor the performance and conditions of systems, structures, and components i
- that perform active functions, the Commission concludes that structures and i
components associated only with active functions can be generically excluded
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from a license renewal aging management review. Functional degradation
.l resulting from the effects of aging on active functions is more readily determinable, and existing programs and requirements are expected to directly detect the effects of aging. (80 FR 22471)
With respect to fire protection equipment, the SOC goes on to clarify that this reasoning applies to installed equipment. The SOC states:
The scope of the maintenance rule does not generally include installed fire protection systems, structures, and components because performance and condition monitoring is required by $50.48. Therefore, for the purposes of license renewal, installed structures and components that perform active functions can be
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generically excluded from an aging management review because they are either within the scope of 6 50.65 or $ 50.48...
i The [ Fire Protection Plan (FPP)] is part of the [ current licensing basis (CLB)] and I
contains maintenance and testing criteria that provide reasonable assurance that l
fire protection systems, structures, and components are capable of performing their intended function. The Commission concludes that it is appropriate to allow license renewal applicants to take credit for the FPP as an existing program that manages the detrimental effects of aging. The Commission concludes that installed fire protection components that perform active functions can be generically excluded from an aging management review on the bar6 of performance or condition-monitoring program afforded by the FPP that are capable of dete'cting and subsequently mitigating the detrimental effects of aging.
60FR22,472-73 (emphasis supplied.)
The development of the list of structures and components that are excluded in 10 CFR 54.21(a)(1)(i) presumes that the structures and components are installed in the plant and are challenged by routine operation or periodic tesung. The logic that was used to screen out systems, structures, and components, that perform active functions e, discussed in the SOCs above does not appear to apply to motors and swMhgears stored in warehouses because they are not challenged by routine operation or periodic tes@g.
The staff recognizes that Section 54.21(a)(1)(i) allows installed motors and switchgears to be excluded from an aging management review. However, it appears to the staff that the pump motors, and switchgear that are stored in warehouses to comply witn Appendix R to 10 CFR Part 50'should be subject to an aging management review in accordance with the intent of the lic~1se rene!al rule.
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i Douglas J. Walters
-3 February 11, 1999 Based on the above, NEl is requested to provide technical justification for why equipment that meets the scoping criteria of 10 CFR 54.4 and is kept in storage can be excluded from an aging management review, Because of the importance of this issue to license renewal, a timely
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resolution it. desirable. The staff has currently assigned a " priority 2" to the resolution of the issue, and would appreciate industry's view regarding this ranking. If you have any questions regarding this matter, please contact Sam Lee at (301) 415-3109.
Sincerely, g
Christoph6~r'l. Grimes, Director License Renewal Project Directorate Division of Reactor Program Management Office of Nuclear Reactor Regulation Project No. 690
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- }4 Douglas J. Walters :
j On the basis of consideration of the effectiveness of existing programs which mon'rc the performance and conditions of systems, structures, and components 4
that perfoim active functions, the Commission concludes that structures arid I
i components associated only with active functions can be generically excluded from a license renewal aging management review. Functional degradation
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resulting from the eNets of aging on active functions is more readily determinable, and existing programs and requirements are expected to directly detect the effects of aging. (60 FR 22471)
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Implicit in the development of the list of structures and coraponents that are excluded in
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.10 CFP. 54.21(a)(1)(i) is the assumption that the structures and components are installed in the 4
l plant and are challenged by constant operation or periodic testing. The logic that was used to j
screen out systems, structures, and components, that perform active functions as discussed in j
the SOCs above does not appear to apply to motors and switchgears stored in warehouses i
because they are not challenged by constant operation or periodic testing.
l The staff recognizes the argument that 54.21(a)(1)(i) allows motors and switchgears to be j
excluded from an aging management review. However, it appears to the staff that the pump
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motors, and switchgear that are stored in warehouses to comply with Appendix R to j
10 CFR Part 50 should be subject to an aging management review in accoidance with the intent of the license renewal rule.
l Based on the above NEl is requested to provide technical justification for why eqaipment that j
meets the scoping criteria of 10 CFR 54.4 and is kept in storage can be excluded from an aging i
management review. Because of the importance of this issue to license renewal, a timely i
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resolubon is desirable. The staff has currently assigned a " priority 2" to the resolution of the issue. *r.J would appreciate industry's view regarding this ranking. If you have any questions r,garding this matter, please contact Sam Lee at (301) 415-3109.
b Sincerely, j-Christopher 1. Grimes, Director l
License Renewal Project Directorate 1
Division of Reactor Program Management Office of Nuclear Reactor Regulation Project No. 690 DOCUMENT NAME:G:\\SEBROSKY\\MOTRS_SC.NEl OFFICE LA PDLR g PDLR:SC M EELB:EE -
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cc: NUCLEAR ENERGY INSTITUTE (NEI)
Project No. 690 cc:
Mr. Denis Harrison
- Mr. Robert Gill U.S. Department of Energy Duke Energy Corporation NE-42 Mail Stop EC-12R j
Washington, D.C. 20585 P.O. Box 1006 Charlotte, NC 28201-1006 Mr. Ricard P. Sedano, Commissioner State Liason Officer Mr. Charles R. Pierce Department of Public Service Southern Nuclear Operating Co.
112 State Street 40 inverness Center Parkway Drawer 20 BIN B064 Montipelier, Vermont 05620-2601 Birmingham, AL 35242 Mr. Barth Doroshuk Baltimore Gas & Electric Company 1650 Calvert Cliffs Parkway Lusby, Maryland 20657-47027 Mr. John J. Carey Electric Power Research Institute 3412 Hillview Avenue Post Office Box 10412 Palo Alto, CA 94303
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